U.S. vessels operating in navigable waters must carry approved nautical charts and publications under federal law. 

The regulatory landscape has shifted significantly since 2020, with NOAA completing its paper chart sunsetting program, the Coast Guard issuing NVIC 01-16 Change 3 in August 2025, and the International Hydrographic Organization (IHO) launching the S-100 framework for next-generation ECDIS. Here is what vessel operators, fleet managers, and maritime compliance officers need to know to stay current and inspection-ready.

Who Does §33 CFR 164 Apply To?

U.S. vessels meeting the applicability parameters in §33 CFR 164.01 must comply with federal carriage requirements for nautical charts and publications as found in §33 CFR 164.33 and §33 CFR 164.72. The applicability parameters are:

(a) Each self-propelled vessel of 1,600 or more gross tons (except as provided in paragraphs (c) and (d), or for foreign vessels described in §164.02) when operating in the navigable waters of the United States except the St. Lawrence Seaway.

(b) Sections 164.70 through 164.82 apply to each towing vessel of 12 meters (39.4 feet) or more in length operating in the navigable waters of the United States other than the St. Lawrence Seaway, except that a towing vessel is exempt from the requirements of §164.72 if it is:

1. Used solely within a limited geographic area, such as a fleeting-area for barges or a commercial facility, and used solely for restricted service, such as making up or breaking up larger tows
2. Used solely for assistance towing as defined by 46 CFR 10.103
3. Used solely for pollution response
4. Any other vessel exempted by the Captain of the Port (COTP), who, upon written request may exempt a vessel from §164.72 for a specified route

(c) Provisions of §§164.11(a)(2) and (c), 164.30, 164.33, and 164.46 do not apply to warships or other vessels owned, leased, or operated by the United States Government and used only in government noncommercial service when equipped with electronic navigation systems that have met the applicable agency regulations regarding navigation safety.

(d) Provisions of §164.46 apply to some self-propelled vessels of less than 1,600 gross tonnage.

Vessel Exemptions

Foreign Vessels

According to §33 CFR 164.02, foreign vessels do not fall under the jurisdiction of these requirements except §164.46(c), and vessels that:

1. Are not destined for, or departing from, a port or place subject to the jurisdiction of the United States; and
2. Are in: (i) Innocent passage through the territorial sea of the United States; or (ii) Transit through navigable waters of the United States which form a part of an international strait.

Foreign flag vessels may be regulated by SOLAS Chapter V 19.2.1 & SOLAS regulation 27, their respective flag state authority (FSA), company administration, and safety management system manual for nautical chart and publication requirements. Administrations, ship owners, fleet managers, and masters should understand these requirements both for compliance purposes and to ensure vessels are operated safely. ANS maintains a comprehensive List of Flag States Requiring Carriage of Publications as a reference resource.

Towing Vessels

A towing vessel is exempt from the requirements of §164.72 if it is:

1. Used solely within a limited geographic area, such as a fleeting-area for barges or a commercial facility, and used solely for restricted service
2. Used solely for assistance towing as defined by 46 CFR 10.103
3. Used solely for pollution response
4. Any other vessel exempted by the Captain of the Port (COTP) upon written request for a specified route.

Government Vessels

Provisions of §§164.11(a)(2) and (c), 164.30, 164.33, and 164.46 do not apply to warships or other vessels owned, leased, or operated by the United States Government and used only in government noncommercial service when equipped with electronic navigation systems that have met the applicable agency regulations regarding navigation safety.

Nautical Chart Carriage Requirements

Commercial Vessels

According to §33 CFR 164.33, for nautical charts to be valid and meet the carriage requirements for U.S. flag vessels, the charts must:

1. Be published by a government hydrographic organization
2. Cover the intended voyage route for the vessel
3. Be large enough scale and provide sufficient navigation data for safe navigation of the area
4. Be corrected to the latest Notice to Mariners (NTMs)

Approved government hydrographic organizations include, but are not limited to:

• United Kingdom Hydrographic Office (UKHO), whose products are available through the ADMIRALTY Nautical Chart catalogue
• National Oceanic and Atmospheric Administration (NOAA)
• National Geospatial-Intelligence Agency (NGA)
• U.S. Army Corps of Engineers (USACE)

Important Update: End of NOAA Traditional Paper Charts. NOAA completed the sunsetting of all 1,007 traditional paper nautical charts and associated raster chart products by January 2025. Traditional lithographic paper charts, raster navigational charts (RNCs), full-size PDF chart images, and BookletCharts have all been cancelled. NOAA's Electronic Navigational Chart (NOAA ENC) is now NOAA's premier and primary nautical chart product. Mariners who still require paper charts can obtain ENC-derived paper charts through the NOAA Custom Chart (NCC) application (version 3.0, released July 2024), which generates charts at customized scales from official ENC data. American Nautical Services offers NOAA NCC print-on-demand charts produced to professional standards, and vessel operators can use the ANS Chart Selector to identify the exact NCC coverage needed for a planned voyage. NCC-produced charts are accepted by the U.S. Coast Guard as meeting carriage requirements when they are up to date and produced at an adequate scale for safe navigation.

U.S. flag vessels engaged solely in domestic voyages may comply with chart carriage requirements by using either electronic charts (ENCs displayed in ECDIS or an approved ECS) or ENC-derived paper charts such as those from the NOAA Custom Chart tool or from other government hydrographic sources, in accordance with the latest guidance in NVIC 01-16 (Change 3, issued August 18, 2025).

U.S. flag vessels engaged solely in domestic voyages may comply with chart carriage requirements by using either electronic charts (ENCs displayed in ECDIS or an approved ECS) or ENC-derived paper charts such as those from the NOAA Custom Chart tool or from other government hydrographic sources, in accordance with the latest guidance in NVIC 01-16 (Change 3, issued August 18, 2025).

Towing Vessels

Towing vessels that fall under the §33 CFR 164.72 regulation must carry:

(1) Charts or maps. Marine charts or maps of the areas to be transited, published by the National Ocean Service (NOS), the USACE, or a river authority that satisfy the following requirements:

(i) The charts or maps must be of a large enough scale and have enough detail to make safe navigation of the areas possible.

(ii) The charts or maps must be either: (A) Current editions or currently corrected editions, if the vessel engages in towing exclusively on navigable waters of the U.S., including Western Rivers; or (B) Currently corrected editions, if the vessel engages in towing seaward of navigable waters of the U.S. or more than three nautical miles from shore on the Great Lakes.

(iii) The charts or maps may be, instead of charts or maps required by paragraphs (b)(1)(i) and (ii) of this section, currently corrected marine charts or maps, or applicable extracts, published by a foreign government. These must contain information similar to that on the required charts, be of large enough scale, have enough detail for safe navigation, and be currently corrected.

ECDIS and Electronic Charting Systems (ECS)

ECDIS

Since the introduction of the Electronic Chart Display and Information System (ECDIS) for digital navigation, ECDIS has become the primary means of navigation in the maritime industry. The U.S. Coast Guard published a notice in 42192 Federal Register / Vol. 69, No. 134 providing their official policy by which ECDIS can meet the chart carriage requirements outlined in §33 CFR 164.33 for U.S. flag SOLAS class vessels and foreign flag vessels transiting to/from the U.S. The Coast Guard considers that an approved ECDIS installed according to SOLAS Chapter V meets the nautical chart regulation in 33 CFR 164.33(a)(1), because the ECDIS addresses the same navigational safety concerns as paper nautical charts.

A SOLAS class vessel can use ECDIS to replace paper nautical charts to satisfy chart carriage requirements under certain conditions:

1. Vessel acquires the necessary Electronic Navigational Charts (ENCs) to be used in ECDIS for the transit. ENCs can be acquired through the Admiralty Vector Chart Service (AVCS) or through other ENC services.
2. Vessel has a functional backup ECDIS on board.
3. ECDIS is fully upgraded to the latest IHO standards.*

*The International Maritime Organization (IMO) has clarified in Circ. 266/rev1 that an ECDIS not upgraded to the latest IHO standards may not meet the carriage requirements as defined in SOLAS Chapter V 19.2.1. Mariners should contact their ECDIS manufacturer to confirm their system is fully upgraded.

Important Update: Transition to S-100 Standards. The IHO has adopted the first set of operational standards within the S-100 framework, with key product specifications (including S-101 for ENCs, S-102 for Bathymetric Surface, S-104 for Water Level Information, and S-111 for Surface Currents) approved in December 2024. The IMO adopted the revised Resolution MSC.530(106) on Performance Standards for ECDIS at its 108th Session in May 2024. From January 1, 2026, S-100 ECDIS is legal for use. From January 1, 2029, all new ECDIS installations must comply with the updated S-100 performance standards. During the transition, "dual-fuel" ECDIS systems can display both S-57 and S-100 products side by side. Mariners should consult with their ECDIS manufacturer about S-100 upgrade pathways. ANS offers an ECDIS Risk Assessment Service to help vessels evaluate readiness for this transition.

ECS

The U.S. Coast Guard's NVIC 01-16 (most recently updated with Change 3, issued August 18, 2025) provides the current policy on the use of Electronic Charting Systems (ECS) and ENCs to satisfy nautical chart carriage requirements in §33 CFR 164.33 for domestic U.S. vessels that voluntarily elect to use electronic charts instead of paper charts.

Key Changes in NVIC 01-16 Change 3: Change 3 replaces Change 2 (signed May 21, 2020) and significantly clarifies the definition of "marine charts," "charts," or "maps" as required by Titles 33 and 46 of the CFR. For this NVIC, these terms can now include data conforming to the IHO's definition of an Electronic Navigational Chart (ENC) or data conforming to the Inland ENC Harmonization Group (IEHG) standard (e.g., Inland Electronic Navigational Chart or IENC). Change 3 also clarifies equivalencies for ENC-derived paper nautical charts and outlines updated inspection procedures for vessels using these equivalencies.

Under NVIC 01-16 Change 3, the following criteria apply to vessels electing to carry electronic charts instead of paper charts:

• ENCs must be of the area to be transited, displayed in a large enough scale, and portray enough detail to make safe navigation of the area possible.
• ENCs, including all updates, must be displayed without any degradation of their information content according to the relevant chart content and display standard.

The original NVIC 01-16 recognized four RTCM ECS classifications. The framework remains relevant, though Change 3 broadens the equivalency provisions:

RTCM Class 'A' ECS: Meets the chart carriage requirements for vessels not on international voyages. The Coast Guard considers RTCM class 'A' to be very similar in functionality to an ECDIS. Mariners in charge of a navigational watch using a class 'A' ECS must possess a successful completion certificate from a Coast Guard-approved ECDIS course and have the appropriate endorsement on their Merchant Mariner Credential (MMC).

RTCM Class 'B' or 'C' ECS: Meets the chart carriage requirements for vessels operating not more than 12 nautical miles from the territorial sea baseline. Mariners who use a class 'B' or 'C' RTCM ECS must be familiar with the ECS before assuming their duties under 46 CFR §15.405.

RTCM Class 'D': Not equivalent to paper marine charts and therefore does not meet the chart carriage requirements prescribed in Titles 33 and 46 of the C.F.R.

Under NVIC 01-16, domestic U.S. flag vessels have two options for backup arrangements when using ECS as the primary means of navigation:

1. An equivalent ECS system that meets the appropriate RTCM standard, connected to a backup power supply separate and independent from the primary navigation system. Backup ECS must be integrated with an external electronic position-fixing device, Automatic Identification System (AIS), Gyro-compass, and Marine Radar if these systems are installed on board. The Coast Guard further recommends integrating a magnetic compass and voyage data recorder if already installed on the ship.
2. A complete portfolio of nautical charts in accordance with 33 CFR part 164 for the intended voyage. Paper chart portfolios may include ENC-derived paper charts, such as those from the NOAA Custom Chart tool.

Vessel owners should be aware that although an RTCM-approved ECS may satisfy domestic carriage requirements, it will not be accepted as SOLAS-compliant for SOLAS certificates by the Coast Guard. A careful review of all requirements for navigation compliance is recommended before committing to the installation of electronic navigation equipment on board.

Nautical Publication Carriage Requirements

§33 CFR 164.33 required publications on board for the intended transit area are:

1. U.S. Coast Pilot (published by NOAA)
2. U.S. Coast Guard Light List
3. Current edition of Tide Tables. Vessels can use tide tables published by private entities as long as they use data from a government hydrographic source.
4. Current edition of Tidal Current Tables. Vessels can use Tidal Current Tables published by private entities as long as they use data from a government hydrographic source.

Vessels may use foreign government nautical publications as an alternative to U.S. nautical publications as long as they cover the intended transit area, are the latest editions, and are fully corrected. U.S. flag vessels may also use digital nautical publications from the United Kingdom Hydrographic Office (UKHO) instead of their paper equivalent. The U.S. Coast Guard has approved the use of digital nautical publications such as Admiralty e-Nautical Publications (e-NPs) and Admiralty Digital Publications (ADP) to meet §33 CFR 164.33 and SOLAS Chapter V carriage requirements in their USCG digital nautical publications acceptance letter to the UKHO. IMO publications in electronic format are also acceptable except for the International Code of Signals and IAMSAR Manual as per IMO Circular MSC-MEPC.2/Circ2.

For vessels managing publications from multiple sources, the SPICA E-Reader consolidates U.S., UKHO, and IMO e-publications into a single centralized platform, allowing bridge teams to access, update, and verify all required digital publications from one interface rather than juggling separate systems for each publisher.

Electronic Publications Policy Update: NVIC 01-16 (Change 2, May 2020, and further clarified in Change 3, August 2025) expanded the policy on electronic carriage of publications. The Coast Guard now considers most electronic devices capable of meeting the "ready reference" requirements. Publications required by Titles 33 and 46 of the CFR, as well as SOLAS Chapter V Regulation 27, may be carried electronically, with most publications accessible via web services. However, if a mariner chooses to use an electronic version of the Inland Navigation Rules and VTS Rules (designated as "ready reference"), the mariner must be able to display current electronic editions on their device without internet connectivity by producing a previously downloaded copy.

Note on Tide and Current Data: NOAA discontinued the authorized publication of annual tide and current tables with secondary station corrections (Tables 2) in 2020. Mariners are now responsible for creating their own appropriate tables for required stations using the data available at tidesandcurrents.noaa.gov. Secondary station corrections still found in older print publications are no longer authorized or dependable.

Required Nautical Charts & Publications: Quick Reference

Disclaimer: American Nautical Services, Inc. assumes no responsibility for the accuracy and contents of this article.The information in this article has been provided for informational purposes only. Mariners should consult with their respective flag state authority, company administration, and safety management system (SMS) to ensure compliance with all current chart and publication carriage requirements on the domestic and international level.

FAQs

Q. Can U.S. flag vessels still use paper nautical charts?

Yes. Although NOAA discontinued traditional paper charts in January 2025, vessels can use ENC-derived paper charts created through the NOAA Custom Chart (NCC) tool or from other government hydrographic sources. ADMIRALTY nautical charts from the UKHO also remain valid for meeting carriage requirements.

Q. Does ECDIS replace the need for paper charts on SOLAS vessels?

An approved ECDIS installed according to SOLAS Chapter V with appropriate ENC licenses and a functional backup ECDIS on board meets §33 CFR 164.33 requirements. No separate paper chart portfolio is required for SOLAS class vessels operating under these conditions.

Q. What is the difference between ECDIS and ECS for compliance purposes?

ECDIS meets both international (SOLAS) and domestic U.S. carriage requirements. ECS provides a domestic-only equivalency under NVIC 01-16 and will not be accepted as SOLAS compliant. Vessel operators on international voyages should use type-approved ECDIS with the Admiralty ECDIS Service.

Q. What changed with NVIC 01-16 Change 3?

Issued August 18, 2025, Change 3 replaces Change 2 and broadens the definition of "marine charts" to include IHO-conforming ENC data and Inland ENCs. The update also clarifies equivalencies for ENC-derived paper charts and provides updated inspection procedures for vessels using electronic chart equivalencies.

Q. When do vessels need to comply with S-100 ECDIS standards?

S-100 ECDIS became legal for use on January 1, 2026. All new ECDIS installations must comply with S-100 performance standards from January 1, 2029. Existing S-57 systems will continue to be accepted during the transition period, and "dual-fuel" ECDIS can display both formats.

Q. Can required publications be carried in electronic format?

Most publications required by 33 CFR and 46 CFR may now be carried electronically per NVIC 01-16. The Coast Guard has specifically approved Admiralty Digital Publications (ADP) and Admiralty e-Nautical Publications as meeting carriage requirements. The Inland Navigation Rules and VTS Rules must be available without internet connectivity if carried electronically. The SPICA E-Reader provides a single platform for managing both U.S. and UKHO digital publications, giving bridge teams centralized access to all required e-publications without switching between separate systems.

Q. How can vessel operators identify the correct charts for a planned voyage?

The ANS Chart Selector allows mariners to search by voyage area and view available paper charts from both the UKHO (ADMIRALTY) and NOAA Custom Charts (NCCs), as well as digital charts from the UKHO. Rather than cross-referencing multiple catalogues manually, operators can use the Chart Selector to identify the specific chart coverage needed for an intended transit and confirm that their folio meets the scale and coverage requirements under §33 CFR 164.33.